On September 18, 2024, Canada announced several rounds of additional sanctions, amending the Special Economic Measures (Iran) Regulations(the “Iran Regulations”), the Special Economic Measures (Hamas Terrorist Attacks) Regulations (the “Hamas Regulations”), and the Special Economic Measures (Extremist Settler Violence) Regulations (the “Extremist Settler Violence Regulations”).
Additional Sanctions Against Iran
These amendments list an additional five individuals in Schedule 1 of the Iran Regulations citing the rapid growth of Iran’s repressive measures against women and its suppression of citizen protests as reasons for implementation. The amended Iran Regulations took effect on September 17, 2024.
The announcement follows the second anniversary of Mahsa Amini’s death, a 22-year-old Iranian woman who died in the custody of Iran’s morality police on September 16, 2022. The newly listed individuals are Iranian political figures with alleged involvement in the creation and carrying out of repressive policies. These sanctions are imposed in coordination with Australia and the United States. Canada has now sanctioned a total of 205 Iranian individuals and 250 Iranian entities.
Additional Sanctions Against Hamas
These amendments list an additional eleven individuals and two entities under the Schedule of the Hamas Regulations in response to Hamas’ terrorist attacks against Israel. The amendments entered into force on September 17, 2024. This is the fourth round of sanctions implemented under the Hamas Regulations since February 2024. The newly listed individuals and entities are alleged to have participated in facilitating, supporting and providing funding related to the planning and execution of the attacks that began on October 7, 2023.
Additional Sanctions Related to Settlements in the West Bank
The amendments list an additional four individuals and two entities under Schedule 1 of the Extremist Settler Violence Regulations. The amendments entered into force on September 17, 2024.
Background Information
The Iran Regulations, Hamas Regulations, and the Extremist Settler Violence Regulations all impose a dealings prohibition against the individuals listed, effectively freezing any assets they hold in Canada. Specifically, the Regulations prohibit any person in Canada and any Canadian outside Canada from:
(a) dealing in any property, wherever situated, that is owned — or that is held or controlled, directly or indirectly — by a designated person;
(b) entering into or facilitating any transaction related to a dealing in a designated person’s property;
(c) providing any financial or related services in respect of a dealing in a designated person’s property;
(d) making available any goods, wherever situated, to a listed person or to a person acting on behalf of a designated person;
(e) transferring or providing any property other than goods to a listed person or to a person outside Canada who is not Canadian for the benefit of a designated person; or
(f) providing any financial or related services to or for the benefit of a designated person.
Individuals listed are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act.
Businesses should continually assess their sanctions compliance in this shifting legal landscape. Regulations enacted under the Special Economic Measures Act obligate persons in Canada and Canadian citizens to disclose certain property held by Schedule 1 parties and any related transactional information to the RCMP. Additionally, certain entities have a continuing duty to determine and disclose certain property of Schedule 1 parties. An unofficial copy of the legislative amendments to the Special Economic Measures (Iran) Regulations, the Special Economic Measures (Hamas Terrorist Attacks) Regulations, and the Special Economic Measures (Extremist Settler Violence) Regulations that came into effect on September 17, 2024 are available on Global Affairs Canada’s website here, here, and here, respectively.
